Hearing Date and Time: August 25, 2010 at 11:00 a.m. (ET) Alan W. Kornberg Andrew J.

Ehrlich PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 1285 Avenue of the Americas New York, NY 10019-6064 Tel. (212) 373-3000 Fax (212) 757-3990 akornberg@paulweiss.com aehrlich@paulweiss.com Attorneys for Apollo Investment Corporation UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: INNKEEPERS USA TRUST, et al., Debtors. Chapter 11 Case No. 10-13800 (SCC) Jointly Administered

RESPONSE OF APOLLO INVESTMENT CORPORATION REGARDING MOTION OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF INNKEEPERS USA TRUST, ET AL., FOR AN ORDER PERMITTING THE COMMITTEE TO CONDUCT RULE 2004 DISCOVERY OF INNKEEPERS USA TRUST, ET AL., AND OTHER PARTIES Apollo Investment Corporation (AIC), by and through its counsel, hereby submits this response (the Response) to the Motion of Official Committee of Unsecured Creditors (the Creditors Committee) of Innkeepers USA Trust, et al., for an Order Permitting the Committee to Conduct Rule 2004 Discovery of Innkeepers USA Trust, et al., and Other Parties [Dkt. No. 222] (the Motion): 1. AIC is committed to providing the Creditors Committee and other parties

in interest with information necessary to address the various matters and disputes arising in these chapter 11 cases. Accordingly, AIC does not object to the Motion and intends to work cooperatively with the Creditors Committee to comply with all reasonable and appropriate discovery requests.

2.

AIC has previously expressed to the Creditors Committee its view that

appropriate steps should be taken to ensure that all discovery in these cases occurs in a streamlined and efficient manner that avoids duplication of time, effort and expense. To that end, AIC has suggested that the parties coordinate with the Debtors and amongst themselves regarding document production and other discovery efforts in connection with this Motion and pending and likely contested matters. AIC expects to work

constructively with the Creditors Committee and the other parties to achieve that goal. 3. AIC continues to work with the Creditors Committee concerning the terms

and scope of the proposed subpoena and is hopeful that agreement on such matters will be reached. 1

Dated: New York, New York August 24, 2010

PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP By: /s/ Alan W. Kornberg Alan W. Kornberg Andrew J. Ehrlich 1285 Avenue of the Americas New York, New York 10019-6064 (212) 373-3000

Attorneys for Apollo Investment Corporation

AIC reserves all of its rights to contest the scope and terms of the proposed subpoena and any other discovery requests by the Creditors Committee or other parties pursuant to Rule 2004 of the Federal Rules of Bankruptcy Procedure or otherwise. The fact that AIC has not objected to the relief requested in the Motion in no way constitutes a waiver of such rights.